Residence tie breaker rules determine tax residency by centre of vital interests, then mutual agreement or place of effective management. The Convention defines resident status by domestic tax criteria: India treats residents as persons liable to tax by domicile, residence, place of ... Summary
Residence tie breaker rules determine tax residency by centre of vital interests, then mutual agreement or place of effective management.
The Convention defines resident status by domestic tax criteria: India treats residents as persons liable to tax by domicile, residence, place of management or similar criteria; Bulgaria treats individuals who are nationals and legal persons with head office or registration in Bulgaria as residents. Dual resident individuals are allocated to the State of their centre of vital interests, with unresolved cases settled by mutual agreement of competent authorities; dual resident entities are resident where their place of effective management is situated.
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